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for failure to pay estimated tax pursuant to section 6654 for 1990 and
1991.
(15) Whether respondent correctly applied the Consumer Price
Index (CPI) to petitioners' 1989 joint return figures to determine
petitioners' 1990 and 1991 tax liability, and to establish asserted
increased liabilities.
Respondent concedes that petitioners are entitled to a filing
status of "married, filing joint return."
FINDINGS OF FACT
Some of the facts have been stipulated. The stipulation of facts
and the attached exhibits are incorporated herein by this reference.
Petitioners were residents of Stockton, California, when they
filed their petitions. Doyle is primarily a real estate broker. In
1990 and 1991, and in prior years, he owned and operated a real estate
brokerage business under the name of Delta Valley Realty (Delta
Valley). During 1990 and 1991, Yvonne worked at Delta Valley as a real
estate agent.
In 1990, Yvonne received non-employee compensation income of
$111,855 from Delta Valley as reported on a Form 1099. In the same
year, she had Form 1099 non-employee compensation income of $1,998
from Phoenix International Marketing Corporation of Sparks, Nevada.
Neither petitioner filed a timely Federal income tax return for
1990 or 1991. However, copies of signed joint returns for 1990 and
1991 were stipulated. Respondent's opening brief states that these
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